CITIZENS FOR CLEAN ENERGY, Inc. www.cce-mt.org
The EIS report has a number of renewable energy alternatives to the SME Highwood Station. In all cases, it found that the alternatives were not equal to the 250 mW coal plant. What is insufficient about those comparisons are that they compare apples to oranges. The following chart shows a true comparison of the renewable energy alternatives to the Highwood Generating Station;
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250 mW Coal-Fired Power Plant |
Renewable Energies/ Combined Heat and Power/ Conservation |
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Cost |
720 million dollars paid over a 30 year period. The debt incurred at the start of construction |
A much smaller incremental amount spent only as the increase in generation is needed |
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Interest on Loan |
Large interest compounded because all 250 mw are installed at once, paid for over the next 30 years |
These installations are added as needed as little as a few kW at a time, to several mW at a time. Significantly less interest on loans. |
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Load Matching Production |
Load must be forecast for 10-20 years in the future. This tends to be done with very low predictability. As we saw with MPC in the early 1980’s where the predicted load was high on Coalstrip 1,2,3,4 causing financial difficulties. Also in the first years of operation close to 50 % of the energy from this plant will be sold on the market making this plant a merchant plant |
Load can be matched almost down to the kW using a combination of power sources with minimal purchase needed from the wholesale market . |
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Method for meeting the Base, Intermediate, and Peaking load requirements of the co-ops and Great Falls ECP |
SME’s plan is to meet Base, Intermediate and Peaking power with a slow to non-modulating base power source. This will require a constant and highly variable need to market excess power. This will be a highly unpredictable process as far as the economics of the operation are concerned. |
Although wind and photovoltaic are not constant or predictable generators, through net metering, they can be reasonably predictable and reliable. They need to be coupled, however, to a firming source which will likely be a combined heat and power distribution generation sources. These are already available and proven in Europe. Systems are available for residential use at 3-10 kW electric with waste heat for domestic hot water and space heat. Commercial systems are available at 20-50 kW up to industrial systems at 250kW – 1-2 mW. Distributive generation has the ability to be a demand peaking source to smooth out residential loads. |
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Social and government acceptance |
Coal is developing a negative connotation because of pollution and climate change. Because of this, power from coal will most likely be penalized monetarily and through regulation. |
Clean, renewable energy has earned an almost universal acceptance. This power will be preferred and receive incentives and can be sold at a premium. |
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CO2 Penalty |
Power from coal plants will either be accessed a carbon tax or require a large investment for carbon sequestration . |
Clean power will benefit from tax incentives, grants and preferences because of its zero CO2 nature. |
615_3rd Ave North Great Falls, MT 59401 (406) 455-6412
CITIZENS FOR CLEAN ENERGY, Inc. www.cce-mt.org
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250 mW Coal-Fired Power Plant |
Renewable Energies/ Combined Heat and Power/ Conservation |
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Adaptability |
Adapting a coal-fired CFB power plant to new technology in 10, 20, or 30 years will be difficult and expensive. |
Because clean energy sources will be added to match the load as it develops over the next 30 years, state-of-the-art equipment will always be easily incorporated into the system and small source upgrades will be easily made at minimal expense. |
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RUS Requirements |
It will take almost 20 years before the Co-op. predicted load matches the 250 mW output of the plant. In order to match the 250 mWs, this plant must operate as a part merchant plant and urban and industrial supply plant. This strays wildly from the RUS Mandate and Mission. |
Clean distributed generation is a perfect fit for a long-term slow growing variable load such as the Co-op’s have. This alternative fits perfectly with the Mandate and spirit of the Co-op’s and RUS. |
From this chart it can be seen that using clean energy sources and distributive generation with combined heat and power (chp) the generation needs could be met in a very different yet very viable manner.
With a renewed emphasis on climate change renewable energy and combined heat and power technology are advancing at an accelerated rate. This is greatly increasing the viability of the technology as well as lowering the price. Add to this the increase in government incentives such as the resent proposal by Sen. Baucus to pay up to 50% of the cost for renewable energy systems on the farm and it is not at all hard to envision a reasonable alternative to SME”s Highwood Generating Station using a combination of solar /wind / distributive generation (combined heat and power) at both the residential and commercial /industrial levels.
An extremely viable option for SME and Great Falls would be to start a program to install photovoltaics, windmills and chp units in as many residences as possible using net metering to interface with the utility. This would help even out the non constant load nature of a residential system. It would facilitate an excellent Way of matching load growth to production. It would minimize risk of the coop to any future co2 related penalties.
Even if a clean energy alternative is not economically competitive at this time it is highly probable that it will be in the near future well within the early 30-40 year life cycle of the Highwood Station and will be significant competition for the plant. With the present growing concern with climate change any analysis of alternatives must assume significant cost penalties on co2 production and significant incentives for clean energy for the foreseeable future.
I feel the FEIS did not investigate what will likely be a significant option and or competitor to the members of SME in the future in the form of a distributed generation systems using solar/ wind / combined heat and power. Because of this omition I feel that it is necessary for RUS to issue a supplemental EIS exploring these very relevant alternatives.
Thank You,
Ken Thornton
615_3rd Ave North Great Falls, MT 59401 (406) 455-6412